SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

Case No. _______________

K. L. SMITH,

Petitioner,

v.

DONALD JOHN TRUMP,

Respondent.

VERIFIED PETITION FOR LEAVE FOR ISSUANCE OF RELIEF

IN THE NATURE OF A WRIT OF QUO WARRANTO

Comes now the Petitioner, in propria persona, stating the following in support of this

Verified Petition for Issuance of Relief in the Nature of a Writ of Quo Warranto:

INTRODUCTION

The controlling law in this case is not amenable to reasonable dispute. First and foremost, the
Fourteenth Amendment is self-executing.1 Second, the unambiguous text of the foundational law

1
This fact is resolved by resort to the bulletproof reasoning of Chief Justice Marshall, in the first case we all studied
in law school:
The constitution is either a superior paramount law, unchangeable by ordinary means, or it is on a level
with ordinary legislative acts, and, like other acts, is alterable when the legislature shall please to alter it.
If the former part of the alternative be true, then a legislative act contrary to the constitution is not law: if
the latter part be true, then written constitutions are absurd attempts, on the part of the people, to limit a
power in its own nature illimitable.

1
that we the People enacted controls. Connecticut Nat’l Bank v. Germain, 503 U.S. 249, 253-54
(1992) (per Thomas, J., collecting cases). Thereunder, any individual who has previously “taken
an oath … to support the Constitution of the United States” and found to have “engaged in insur-
rection or rebellion against the same” shall not “hold any office, civil or military, under the United
States,” unless Congress, in their infinite wisdom, “by a vote of two-thirds of each House, re-
move[s] such disability.” U.S. Const. amend. XIV, § 3. And most importantly, as a matter of
law, the actions of a usurper are void ab initio:
[W]hen the constitution or form of government remains unaltered and supreme, there
can be no de facto department, or de facto office. The acts of the incumbents of such
departments or office cannot be enforced conformably to the constitution, and can be
regarded as valid only when the government is overturned.

Norton v. Shelby County, 118 U.S. 425, 443 (1886).2

It is a hard ban. Like the requirement that a Senator be over thirty, have been a citizen for at
least nine years, and an inhabitant of the State you purport to serve. U.S. Const. art. I, § 3, cl. 3.

Marbury v. Madison, 5 U.S. 137, 177 (1803).

There is no support in precedent or logic for the proposition that a constitutional provision must be activated by
formal legislation to become effective. E.g., United States v. Stanley (Civil Rights Cases), 109 U.S. 3, 20 (1883) (“the
Thirteenth amendment, as well as the Fourteenth, is undoubtedly self-executing without any ancillary legislation”),
City of Boerne v. Flores, 521 U.S. 507, 524 (1997) (Fourteenth); South Carolina v. Katzenbach, 383 U.S. 301, 325
(1966) (Fifteenth).
Any doubt on this score was laid to rest by the tale of Col. Nathan Tift. Upon the readmission of Georgia to repre-
sentation, Tift was elected as a Democrat to the Fortieth Congress. The Fourteenth Amendment was ratified on July
9, 1868—presumably, while Tift was en route. But rather than remove Tift’s disability, Congress passed a private bill
enabling him to serve out that Term—but no more. “Congress enacted a private bill to remove the Section 3
disability of Nelson Tift of Georgia, who had recently been elected to represent the State in Congress. See ch. 393, 15
Stat. 427. Tift took his seat in Congress immediately thereafter. See Cong. Globe, 40th Cong., 2d Sess., 4499-4500
(1868).” Trump v. Anderson, 601 U.S. 100, ___, 144 S. Ct. 662, 669 & n.2. But Georgia sent six secessionists to the
Forty-First Congress which the members refused to seat, including Nathan Tift. Biographical Directory: Forty-First
Congress at 179 & fn. 11, https://www.govinfo.gov/content/pkg/GPO-CDOC-108hdoc222/pdf/GPO-CDOC-
108hdoc222-3-41.pdf
2
This conclusion is consistent with our concept of popular sovereignty, foreign to our British forebears. The Framers’
views were consonant with that of Locke, who maintained that a usurper could never attain legitimate power. John
Locke, Second Treatise of Government ch. XVIII (1689). E.g., John Adams, Novanglus No. 5, Feb. 20, 1775; Thomas
Jefferson, Kentucky Resolution (1798) (acts in excess of jurisdiction are void ab initio); George Washington, Farewell
Address (Sept. 19, 1796) (the Constitution is the outer boundary of popular consent); Federalist No. 84 (Hamilton)
(same). The stirring prose of Thomas Paine distills the thought. “[I]n America THE LAW IS KING. For as in
absolute governments the King is law, so in free countries the law ought to be King; and there ought to be no other.”
Thomas Paine, Common Sense (Philadelphia, R. Bell, 1776) (emphasis in original), reprinted in pt. III, ¶ 103 (Project
Gutenberg, 1994). As long as we remain governed by the Constitution, either an occupant of an office has a legal
right to discharge the duties of an office, or s/he does not. There is no third option.
This is in direct contrast to the experience in medieval England during the Wars of the Roses (1455-1487), where
factions vied over the kingship. As it wasn’t entirely clear who the actual King was, Parliament enacted The Treason
Act, 11 Hen. VII [1495], c. 1 (“noe person going wth the Kinge to the Warres shalbe attaynt of treason”), creating the
de facto officer doctrine. Translated from the Middle English, it forbade legal punishment of subjects who followed
the orders of the de facto king, irrespective of whether he was legitimate or a usurper. Importantly, it is NOT a
common-law doctrine.

2
You have to be twenty-one to get into the strip club. The only difference is that it is not necessarily
a permanent ban. U.S. Const. amend. XIV, § 3.
The only question of law properly before the Supreme Court in Trump v. Anderson was whether
“the Colorado Supreme Court err[ed] in ordering President Trump excluded from the 2024 presi-
dential primary ballot,” Trump v. Anderson, No. 23–719, 601 U.S. 100 (2024), Pet. Br. at (i). As
such, the question of whether Trump could legally serve as President was never before the Court.
Accordingly, the only facts that matter—that Trump took the requisite oath, and that he had en-
gaged in insurrection—were left undisturbed. The doctrine of collateral estoppel prohibits reliti-
gation of an issue of fact or law that has been decided in earlier litigation. But more importantly,
the Anderson majority’s assertion that Congress somehow has to pass a law to effectuate Section
3 is not just comically ahistorical, but obiter dictum. As there is no reason why Congress couldn’t
remove Trump’s disability even now, there was no reason why he couldn’t have stood for elec-
tion—as Col. Tift did. Trump v. Anderson was correctly decided 9-0, on the only question properly
before it.
But it gets worse. Writing for the Court, Chief Justice Roberts confessed that “Members of this
Court are vested with the authority to interpret the law; we possess neither the expertise nor the
prerogative to make policy judgments. Those decisions are entrusted to our Nation's elected lead-
ers, who can be thrown out of office if the people disagree with them.” Nat. Fedn. of Indep. Busi-
ness v. Sebelius, 567 U.S. 519, 132 S.Ct. 2566, 2579 (2012). This sua sponte addition to the text
of the Anderson opinion was pernicious and corrupt—which just about sums up the Roberts Court.
Every Justice in the Anderson majority—Roberts, Thomas, Alito, Gorsuch, Kavanaugh, Barrett—
has publicly admitted that they can’t change the Constitution to suit their pleasure, and five hun-
dred years’ worth of precedent confirms this.3 But even that couldn’t stop them….
3
(Roberts: “Judges have power to say what the law is, not what it should be.” Obergefell v. Hodges, 576 U.S. 644,
135 S.Ct. 2584, 2811 (2015) (Roberts, C.J., dissenting); Thomas: “Judicial power… is never exercised for the purpose
of giving effect to the will of the Judge.” Gamble v. United States, 587 U.S. 678, 139 S.Ct. 1960, 1982 (2019) (Thomas,
J., concurring); Alito: “It is the job of a judge… to interpret the Constitution, not distort [it],” Confirmation Hearing
on the Nomination of Samuel A. Alito, Jr. To Be an Associate Justice of the Supreme Court of the United States:
Hearing Before the S. Comm. on the Judiciary, 109th Cong. 465 (2006) (statement of Samuel A. Alito, Jr.); Gorsuch:
“Ours is the job of interpreting the Constitution… according to its original public meaning,” Cordova v. City of Albu-
querque, 816 F.3d 645, 661 (10th Cir. 2016) (Gorsuch, J, concurring); Kavanaugh: “The Constitution does not grant
[us] unilateral authority to rewrite” it, Dobbs v. Jackson Women’s Health Organization, 597 U.S. 215, __, 142 S.Ct.
2228, 2306 (2022) (Kavanaugh, J. concurring); Barrett: “Partisan politics are not a good reason for deciding a case.”
Amy C. Barrett, Precedent and Jurisprudential Disagreement, 91 Tex. L. Rev. 1711, 1729 (2012-13)).
For five centuries, it has been universally understood that the office of the judge "is jus dicere, and not jus dare; to
interpret law, and not to make law, or give law." Francis Bacon, Essays LVI (Of Judicature) (1620). Mindful that “the
discretion of the judge is the first engine of tyranny," 4 C. Gibbon, The History of the Decline and Fall of the Roman
Empire 385 (1776-89) (Philips Samson, and Co. 1856), Alexander Hamilton argued that to "avoid an arbitrary discre-
tion in the courts, it is indispensable that [judges] should be bound by strict rules and precedents, which serve to define
and point out their duty in every particular case before them." The Federalist No. 78, 470 (I. Kramnick ed. 1987)
(Alexander Hamilton). Blackstone asserted that the judge’s duty to follow precedent derived from the nature of the
judicial power itself: a judge is "sworn to determine, not according to his own judgments, but according to the known
laws." 1 Blackstone, Commentaries at 69. A century earlier, Coke observed that "[i]t is the function of a judge not to
make, but to declare the law, according to the golden mete-wand of the law and not by the crooked cord of discretion."
1 E. Coke, Institutes of the Lawes of England 51 (1642).
Professor (Justice) Story adds that “A more alarming doctrine could not be promulgated by any American court,
than that it was at liberty to disregard all former rules and decisions, and to decide for itself [what the law is], without
reference to the settled course of antecedent principles.” 1 J. Story, Commentaries on the Constitution of the United

3
 Under the Framers’ Constitution, the citizen was not an idle spectator. As Harvard’s legendary
Raoul Berger proved, every citizen enjoyed standing in public interest cases.4 In England, "[e]very
subject,' said Justice Lush, "has an interest in securing that public duties shall be exercised only by
those competent to exercise them .... "5 The law was identical on both sides of the Pond until the
Taft Court invented ‘standing’ as part of their crusade to turn “Supreme Court Justice” into a part-
time job in Frothingham v. Mellon, 262 U.S. 447 (1923). Moreover, Professor Berger adds that
“[n]o hint that judicial restraint of legislative usurpation was to hinge on the suitor's ‘interest’ is to
be found in the records of the Constitutional Convention.” Berger, Standing to Sue at 829. Pro-
fessor Jaffe concurs, arguing that "the public action—an action brought by a private person pri-
marily to vindicate the public interest in the enforcement of public obligations—has long been a
feature of our English and American law." Louis L. Jaffe, Standing to Secure Judicial Review:
Private Actions, 75 Harv. L. Rev. 255, 302 (1961). (I have standing and will plead those facts, but
this is strictly unnecessary.)

The right to have public duties exercised by “those competent to exercise them” is a common
law right, for which there was a remedy enforceable in chancery court. "The common law ... ought
not to be deemed to be repealed, unless the language of a statute be clear and explicit for this
purpose," Fairfax's Devisee v. Hunter's Lessee, 11 U.S. 603, 623 (1813); accord, United States v.
Texas, 507 U.S. 529, 534 (1993) (quotations and citations omitted). All the common law writs
were available. Judiciary Act of 1789, ch. 20, § 14, 1 Stat. 73, 81-82 (1789). The practice is con-
sistent with the Framers’ design, the common law, and the concept of popular sovereignty.6

States 350 (1838). The judge was expected to be little more than an administrator, playing what Professor Llewellyn
called “the game of matching cases.” Karl Llewellyn, The Bramble Bush 49 (1960).
Under our system, the judicial power is “to decide what the law is, not to declare what it should be,” Minor v.
Happersett, 88 U.S. 162, 178 (1874), for as long as judges are at liberty to “substitute their own pleasure to the con-
stitutional intentions of the legislature,” The Federalist No. 78 at 440 (Alexander Hamilton)—or the people—it can
no longer honestly be said that we are a nation governed by laws. The rewriting of the Constitution under a false
pretense of interpreting it is “a flagrant perversion of the judicial power.” Heiner v. Donnan, 285 U.S. 312, 331 (1932).
In the timeless words of Justice Holmes, it is ‘an unconstitutional assumption of powers by courts of the United States
which no lapse of time or respectable array of opinion should make us hesitate to correct.” Erie R.R. Co. v. Tompkins,
304 U.S. 64, 79 (1938). "Courts are constituted by authority and they can not go beyond the power delegated to them.
If they act beyond that authority, and certainly in contravention of it, their judgments and orders are regarded as
nullities." Vallely v. Northern Fire & Marine Ins. Co., 254 U.S. 348, 353 (1920). There is no contrary authority.
4
Raoul Berger, Standing to Sue in Public Actions: Is it a Constitutional Requirement?, 78 Yale L.J. 816, 819 (1969)
(“No English court, so far as I can discover, has ever rejected the authority of Articulo Cleri or denied that a writ of
prohibition may be granted at the suit of a stranger.”). In particular, quo warranto was available to a stranger in Rex
v. Smith [1790] 100 Eng. Rep. 740, wherein it was observed that “the ground on which this application is made is to
enforce a general Act of Parliament, which interests all the corporations in the kingdom; and therefore it is no objection
that the party applying is not a member of the corporation." Berger, 78 Yale L.J. at 823 & n. 38.
5
Berger, Id. at 823 & n. 39 (“In 1915, Lord Reading observed that "a stranger to a suit can obtain prohibition. ... and
I see no reason why he should not in a proper case obtain an information of quo warranto." … "Every subject,' said
Justice Lush, "has an interest in securing that public duties shall be exercised only by those competent to exercise
them .... ").
6
Collusive suits without adverse parties fail the “Cases or Controversies” test of Article III, § 2, cl. 1, Muskrat v.
United States, 219 U.S. 346 (1911). The Privy Council gives advice to the Crown; beyond that, the concept of advisory
rulings appears foreign to the common law. See Ashby v. White [1703] 92 Eng. Rep. 126, 136 (H.C.) (for every right,
there must be a remedy).

4
 This self-evident axiom is proven by the obverse: Our servants in government work for us, but
we have no way of ensuring that they act within the bounds of their agency? To even state the
case is to refute it.

Justice Barrett graciously drove the final nail in the coffin of the constitutional Dracula’s Coffin
that is judicial lawmaking. In declaring that the nationwide injunction is obviously void because
it cannot be traced to the Constitution,7 she necessarily casts aspersions on the judicial rewrites of
the Fourth,8 Seventh,9 Ninth (in Dobbs, supra., reducing it to Bork’s inkblot), Eleventh, Alden v.

7
Specifically, speaking for the Court, she chastised Justice Jackson last week in a frameworthy rant:

We will not dwell on JUSTICE JACKSON’s argument, which is at odds with more than two centuries’
worth of precedent, not to mention the Constitution itself. … JUSTICE JACKSON would do well to
heed her own admonition: “[E]veryone, from the President on down, is bound by law.” Ibid. That goes
for judges too.

Trump v. CASA, Inc., No. 24A884, 606 U.S. ___ (2025) (Application for Stay granted Jun. 27, 2025), slip. op. at 23,
24 (capitalization in original) (emphasis added).
You would almost think she disapproved of judicial lawmaking.
8
As a matter of law and logic, a right cannot exist without an effective remedy for its breach, Ashby v. White [1703]
92 Eng. Rep. 126, 136 (H.C.), and “[t]o take away all remedy for the enforcement of a right is to take away the right
itself.” Poindexter v. Greenhow, 114 U.S. 270, 303 (1884). Bivens v. Six Unknown Federal Narcotics Agents, 403
U.S. 388 (1971), is bad law because it is too narrow. In simple terms, Egbert v. Boule, 596 U.S. 482 (2022), went the
wrong way, taking away more rights by forestalling remedies. Cf., Jacobs v. United States, 290 U.S. 13, 16 (1933)
(Fifth Amdt. takings clause an implied waiver of sovereign immunity).
9
The right to a trial by jury preserved by the Seventh Amendment is that which existed at common law at the time
the Amendment was adopted, Baltimore & Carolina Line, Inc. v. Redman, 295 U.S. 654, 657 (1935), and the signal
feature of the jury trial in 1791 was that the jury—not judges!—had lawful authority to “determine the law as well as
the fact in controversy.” Georgia v. Brailsford, 3 U.S. 1, 4 (1793) (jury instructions of Jay, C.J.). By taking ultimate
decision-making power out of the hands of judges, the Seventh Amendment preserved one of the "transcendent priv-
ileges" of the Englishman: "that he cannot be affected either in his property, his liberty, or his person, but by the
unanimous consent of twelve of his neighbours and equals.” 4 Wm. Blackstone, Commentaries on the Laws of England
*379 (1765).
To the Framers’ generation, the right to a jury trial, with one’s peers deciding both the facts and law, was a sacro-
sanct privilege of citizenship: they fought a revolution to secure it; several Framers refused to sign the Constitution
because it did not adequately preserve it. Justice Rehnquist drives this point home: “The founders of our Nation con-
sidered the right of trial by jury in civil cases an important bulwark against tyranny and corruption, a safeguard
too precious to be left to the whim of the sovereign, or, it might be added, to that of the judiciary.” Parklane Hosiery
Co., Inc. v. Shore, 439 U.S. 322, 343, (1979) (Rehnquist, J., dissenting) (emphasis added).
On this point, the Framers’ intent could not have been more pellucid. The express purpose of this “Heaven-taught
institution,” Fabius, Letter to Editor, Delaware Gazette (1788), reprinted in, John Dickinson, The Letters of Fabius,
in 1788, on the Federal Constitution; and in 1797 on the Present Situation of Public Affairs 32 (1797), was “to guard
agst. corrupt Judges,” 2 Farrand, The Records of the Federal Convention of 1787 587 (1909) (statement of Elbridge
Gerry (MA)); reducing them to glorified consiglieri. As Thomas Jefferson explained, it is left “to the juries, if they
think the permanent judges are under any biass whatever in any cause, to take upon themselves to judge the law as
well as the fact. They never exercise this power but when they suspect partiality in the judges, and by the exercise of
this power they have been the firmest bulwarks of English liberty.” Thomas Jefferson, Letter (to L’Abbe Arnoux),
Jul. 19, 1789 at 2. There is no contrary authority.
Chase was impeached for, among other offenses, refusing to allow a defendant’s lawyer to argue the law before
the jury, as the Framers had intended: Samuel H. Smith & Thomas Lloyd, Trial of Samuel Chase, an associate justice
of the Supreme Court of the United States, impeached by the House of representatives, for high crimes and

5
Maine, 527 U.S. 706 (1999) (effectively adopting the version the Amendment’s framers explicitly
rejected; see John Paul Stevens, "Two Questions About Justice," 2003 Ill. L. Rev. 821 (proving
this point))—and most importantly for purposes of this matter, the disembowelment of Section 3
of the Fourteenth in Trump v. Anderson.

The tale of Nathan Tift is controlling precedent. That the framers of the Fourteenth Amendment
intended it to be self-executing is proven by their conduct: If they needed to pass legislation to
effectuate it, they wouldn’t have needed to pass a private bill to let him into the Fortieth Congress,
and would have had no right to exclude him from the Forty-First.

Fiat iustitia, ruat cœlum!!! Let justice be done, though the heavens fail. The Constitution
does not only apply when applying it is easy. The systematic failures that led to the ascension of
Donald Trump will not be easy to unwind, but “easy” is not an element of any cause of action that
I learned of in law school. The pardons? Void. The Executive Orders? Void. Allegator Ausch-
witz? Closed. The One Big Billionaire Bailout? A nullity. (You need the signature of a President
to make a law.) The EPA and National Weather Service? Restored. But the longer this is delayed,
the harder that this will be to unwind. Time, therefore, is of the essence.

The Constitution is our national catechism. And thereunder, “Everyone, from the President on
down, is bound by law. That goes for judges too.” I can’t argue with Justice Barrett or Justice
Jackson on this point. This case isn’t about right or left; it’s about right and wrong.

VERIFIED PETITION FOR RELIEF

1. Petitioner K.L. SMITH, a United States citizen and resident, respectfully submits this peti-

tion as a relator in the public interest to challenge the unlawful holding or exercise of a public

office, pursuant to D.C. Code § 16-3503.

2. As a United States citizen, I am harmed by Respondent DONALD JOHN TRUMP’s unlaw-

ful exercise of the office of the Presidency, which undermines constitutional governance and the

rule of law, affecting my rights and the public’s interest in lawful administration.

3. Petitioner swears under penalty of perjury that, for reasons stated herein, the Respondent’s

occupation of the office of the Presidency violates Article II, Section 1, Clause 5 of the United

misdemeanors, before the Senate of the United States 25–26 (Washington, Samuel H. Smith 1805). Ten years before-
hand, Chief Justice Jay instructed a jury: “But it must be observed that by the same law, which recognizes this rea-
sonable distribution of jurisdiction, you have nevertheless a right to take upon yourselves to judge of both, and to
determine the law as well as the fact in controversy.” Georgia v. Brailsford, 3 US 1, 4 (1794). And if an attorney
ever tried that in this Court, he would have to have an unpleasant chat with the Bar.

6
States Constitution, as an oathbreaking adjudged insurrectionist may not serve in that office unless

and until Congress, “by a vote of two-thirds of each House, remove[s] such disability.” U.S. Const.

amend. XIV, § 3.

4. Venue is proper in this matter as the office of the Presidency is located at 1600 Pennsylva-

nia Avenue, Washington, DC 20500, and a significant portion of the actions pertinent to this matter

either have occurred or will occur within this District, and Respondent is subject to jurisdiction

there. 28 U.S.C. § 1391(b).

5. Jurisdiction is conferred by D.C. Code § 16–3501 (usurpation).

6. “The Attorney General of the United States or the United States attorney [for the District]

may institute a [quo warranto] proceeding … on his own motion.” D.C. Code § 16–3502.

7. “If the Attorney General or United States attorney refuses to institute a quo warranto pro-

ceeding on the request of a person interested, the interested person may apply to the court by

certified petition for leave to have the writ issued.” D.C. Code § 16–3503.

8. Whereas it is normally customary and proper for a petitioner to defer to the Attorney General

and/or United States Attorney, both are nominally answerable to the President, and hyper-partisan

supporters of the person whose right to occupy the office is challenged herein:

7
 [Petitioner is acutely aware that the allegations summarized below are serious and in some
instances unproven. They are not offered to establish criminal liability but rather, to demon-
strate that both the Attorney General and interim U.S. Attorney suffer from grievous and
publicly documented entanglements and credibility issues that render any expectation of
good-faith action under D.C. Code § 16–3502 objectively unreasonable.]

a. Pamela Jo Bondi has been an ethical train-wreck since she burst onto the national scene.

1. “When You Give, They Do Whatever the Hell You Want Them To Do”
Trump became acquainted with Bondi when he gave her a $25,000 bribe campaign con-
tribution from one of his charities to get rid of the Trump University investigation. Jose
Pagliery, The Real Story Behind the $25,000 Trump Donation to Pam Bondi, The Daily
Beast, Aug. 26, 2021, The Orlando Sentinel’s Scott Maxwell summarizes the case:
One day, Bondi’s office told this newspaper it was reviewing complaints from Floridi-
ans who said they felt swindled by the Trump Institute affiliate of Trump University.
Four days later, Trump’s foundation cut a $25,000 check to Bondi’s campaign commit-
tee.
Then, after the check came in, her office decided not to take any action against Trump.
Bondi — whose own spokesman said Bondi personally asked Trump for the money —
says the two things weren’t related. …
Imagine you were robbed and the prosecutor gave the suspect a pass after taking
$25,000 from him. There would be universal outrage — and rightfully so. This is not
the behavior of an ethical prosecutor.

Scott Maxwell, New records show Bondi needs probing in Trump mess, Maxwell says, Or-
lando Sentinel, updated Jun. 12, 2018 (original Sept. 2016). And for his part, Trump doesn’t
deny it: “As a businessman and a very substantial donor to very important people, when you
give, they do whatever the hell you want them to do,” Trump told the Wall Street Journal
in July 2015.” Nick Gass, Trump's pay-for-play scandal intensifies, Politico, Sept. 7, 2016
(emphasis added).

An ethical prosecutor would not accept the check. In that incident, Bondi displayed the
lack of personal character that made her a perfect fit for the second Trump Administration.

2. Loyalty Before Honesty

The most concerning manifestation is that she has used her offices for political purposes
is when she fired a line attorney for the unforgivable sin of telling the truth to a tribunal in
the Abrego-Garcia case. Sadie Gurman, He Represented Contentious Immigration Cases
for the Government. His Candor Lost Him His Job, Wall St. J., Apr. 15, 2025. But by far
the most alarming act by Trump’s appointees was the wholesale firing of prosecuting dozens
of prosecutors for the unthinkable act of … prosecuting people for participating in the

8
 insurrection on January 6th. Kyle Cheney and Josh Gerstein, DOJ fires dozens of prosecutors
who handled Jan. 6 cases, Politico, Jan. 31, 2025.10

On its face, this presents itself as a deliberate campaign of retribution.

3. Pedophile Games: Making the Epstein Scandal ‘Go Away’

Bondi is also in the news for making the Epstein scandal ‘go away.’ “’You still talking
about Jeffrey Epstein?’ Mr. Trump, visibly exasperated, asked a reporter at a cabinet meeting
on Tuesday, the day after the Justice Department released a memo concluding that ‘no fur-
ther disclosure would be appropriate or warranted’ in the investigation of Mr. Epstein.”
Glenn Thrush and Stuart A. Thompson, Confronted Over Epstein Files, Trump and Bondi
Tell Supporters to Move On, N.Y. Times, Jul. 8, 2025. This appears to be calculated to
protect Trump, who is all over the files and credibly identified as “Doe #174.” E.g., Tom
Norton, Is Donald Trump 'Doe 174' in Jeffrey Epstein Documents? What We Know,
Newsweek, Jan. 10, 2024 (Business Insider did the heavy lifting, but their story is now behind
a paywall). Before he met his untimely demise, Epstein claimed Trump as one of his besties
for decades11 and, in the words of James Comey, “Lordy, there are tapes!” “[Journalist Mi-
chael] Wolff claims the excerpt tape is a mere fraction of some “100 hours of Epstein talking
about the inner workings of the Trump White House and about his longstanding, deep rela-
tionship with Donald Trump.” Edward Helmore, Jeffrey Epstein details close relationship
with Trump in newly released tapes, The Guardian (U.K.), Nov. 1, 2024. A witness told
investigators that Trump “had sex with many girls.” Jen Smith, et al., Donald Trump named
in latest Epstein documents: Sarah Ransome said he had sex with 'many girls' in email where
she also claimed pedophile had tapes of the ex-president, Richard Branson, Prince Andrew,
Bill Clinton, DailyMail (U.K.), Jan. 8, 2024. Alan Dershowitz, who represented Epstein in
the infamous 2008 plea deal, Ben Sales, Dershowitz Has No Regrets Over Role in Jeffrey
Epstein’s 2008 Plea Deal, Ha’aretz, Jul. 15, 2019, claims that he has seen all the documents.
Sean Spicer, Alan Dershowitz: "I've Seen ALL the EPSTEIN DOCUMENTS," YouTube,
https://www.youtube.com/watch?v=8Esfvoxrm9g (April, 2025).

Powerful men, raping children with impunity? Yeah, we’re still talking about it.

4. The Dog Ate My Homework: The Mystery of the Disappearing Files

10
It did not end there. Lifer Denise Cheung was forced to resign, rather than pursue a criminal case without what she
concluded was adequate predication. Read the resignation letter by Denise Cheung, a veteran D.C. federal prosecutor,
Wash. Post, Mar. 6, 2025. Trump commands an army of berserkers who stand ready to do his bidding, and Bondi
seems to be leading the charge. See David Gardner, Pam Bondi Warns ‘Deranged’ Judges: ‘We Are Coming for You’,
Daily Beast, Apr. 25, 2025. Instead of emphasizing loyalty to the Constitution, she demands loyalty to the President:
“The discretion afforded Department attorneys entrusted with those responsibilities does not include latitude to sub-
stitute personal political views or judgments for those that prevailed in the election.” Pamela Bondi, “General Policy
Regarding Zealous Advocacy on Behalf of the United States,” Memo, Feb. 5, 2025.
11
Trump defenders claim that the fact that Epstein was barred from Mar-a-Lago is conclusive evidence that he was
not part of the debauchery. Unsurprisingly, that has been called into question. Bess Levin, Of Course Trump “Fell
Out” with Epstein Over Real Estate, Not Underage Girls, Vanity Fair, Aug. 1, 2019. Less than three weeks after the
incident, the Feds got an anonymous tip from someone with intimate knowledge of the operation. Trump is notori-
ously vindictive. The list of suspects is short.

9
 12

Do (or shall I say, “did”) the tapes exist? Ransome’s claims are corroborated by none
other than Bondi herself. In her own voice, more than once. “There are tens and thousands
of videos and its all with little kids.” According to the Associated Press, “Bondi appeared
at the White House, where she said: ‘There are tens of thousands of videos of Epstein with
children or child porn.’” Eric Tucker and Alanna Durkin Richer, Takeaways from AP’s re-
port on Attorney General Bondi’s comments about evidence in Epstein case, Assoc. Press,
Jul. 1, 2025.13
This might be less problematic, but for an interview on Fox News, where a host asked:
“DOJ may be releasing a list of Jeffrey Epstein’s clients; will that really happen?” While he
asked, Bondi nodded her head in agreement. Her response: “It’s sitting on my desk right
now.”14 Add that to the one minute of missing surveillance video, Kelly Rissman, Minute-
gap in Jeffrey Epstein jailhouse video released by DOJ fuels conspiracy theories, The Inde-
pendent (U.K.), Jul. 8, 2025, a suit by victims alleging that the FBI was engaged in a coverup,
Jonathan Stempel, Jeffrey Epstein victims sue FBI, allege coverup, Reuters, Feb. 14, 2024,
the reactions of victims, Juliette Rose Bryant, X (July 8, 2025, 3:06 PM), https://x.com/Ju-
lietteBryant/status/1942601265130922084 (“victims are being found dead”), and the about-
face is incriminating on its face. Jack Silver, Pam Bondi Has Yet to Explain Where the
‘Tens of Thousands’ of Epstein Child Porn Videos Are, Daily Beast, Jul. 1, 2025.15

12
O’Keefe Media Group, X (July 8, 2025, 10:35 PM), https://x.com/OKeefeMedia/status/1942714206840615065.
13
Veteran investigative reporter Tara Palmeri alleges that her FBI sources tell us that the tapes exist, Tara Palmeri,
Pam Bondi has no credibility on Jeffrey Epstein, The Tara Palmeri Show (Youtube video), Jul. 8, 2025,
https://www.youtube.com/watch?v=D5xKJT_jKuk, and a 60 Minutes producer reportedly tricked Ghislane Maxwell
into admitting that tapes existed. Daniel Bates, Ghislaine Maxwell admitted Jeffrey Epstein DID have tapes of Trump
and the Clintons after she was tricked by 60 Minutes producer in 2016 - 'but refused to help locate them because she
wanted Hillary to win', DailyMail (U.K.), Feb. 18, 2021.
14
Robby Starbuck, X (July 7, 2025, 2:42 AM), https://x.com/robbystarbuck/status/1942051481542160409. ; the em-
bedded video is what matters. From the clues on the screen, it was likely aired on Feb. 21, 2025 at 1:11 P.M. EST, as
Lara Trump’s show was to premiere the next day.
15
The only way those files disappear is that they get disappeared, and it would be truly remarkable if Epstein didn’t
keep tapes. Whether he was part of a Mossad or even KGB honeypot operation can be left to speculation, but there is
credible evidence that Trump did rape a 14-year-old girl going under the pseudonym “Katie Johnson.” Tufayel Ahmed,
Trump Teen Rape Allegation Resurfaces, Ronan Farrow Claims National Enquirer Tried to Protect Him in New Book,
Newsweek, Oct. 6, 2019, and in 2010, “Epstein pled the Fifth when asked by a lawyer representing one of Epstein’s
victims about his relationship with Trump.” Ken Silverstein, The Salacious Ammo Even Donald Trump Won’t Use
in a Fight Against Hillary Clinton, VICE, Jan. 29, 2016. There is credible evidence that Trump raped young ‘Katie,’
http://thememoryhole2.org/blog/doe-v-trump, and the existence of a video proving it would be a powerful weapon in
the hands of either Vladimir Putin or Bibi Netanyahu, and in turn, that seems to have affected our foreign policy.

10
 Politically, going after Epstein’s johns might be the easiest sell since ice in the desert,
and Trump’s MAGA base is having kittens over it.16 So, why is she closing the case? The
only logical answer is that Attorney General Bondi appears to be using her office for the
purpose of protecting Donald Trump. It logically follows that AG Bondi would never pros-
ecute a case that would remove her long-time patron from office.

b. Jeanine Ferris Pirro is an infamous partisan flamethrower, known more for her cable
TV show than her legal prowess. She hasn’t darkened the door of a courtroom for well over
a decade, and is serving as the INTERIM U.S. Attorney because even Trump does not think
she stands a snowball’s chance in hell of being confirmed. Paul Schwartzman, et al., TV-
ready, loyal: Pirro, Trump’s pick for top D.C. prosecutor, fits his mold, Wash. Post, May 9,
2025. She replaced former Interim U.S. Attorney Ed Martin, “after 15 tumultuous weeks in
office marked by his threats to investigate Trump’s perceived political adversaries and fir-
ings and demotions of career prosecutors who handled cases involving the president and the
Jan. 6, 2021, U.S. Capitol attack.” Spencer S. Hsu, et al., Trump replaces D.C. U.S. attorney
Ed Martin with Fox News host Jeanine Pirro, Wash. Post, May 8, 2025.
Pirro has never tried to hide her partisanship. “From the outset of the administration, she
has used her TV platform to hammer the president’s critics and to ding his allies, including
[former AG] Sessions, as insufficiently loyal. She recently described the attorney general as
the biggest threat to the Trump agenda, calling him “the most dangerous man in America.”
Eliana Johnson and Andrew Restuccia, Trump dangled administration job to Judge Jeanine,
Politico, Jun. 7, 2018. What Pirro either doesn’t understand or doesn’t care to is that DOJ
attorneys take an oath “to support and defend the Constitution,” 5 U.S. Code § 3331, not the
President. Lauren Miller Karalunas, Presidents Can’t Use the Justice Department as Their
Personal Law Enforcement Agency, Brennan Center for Justice, Feb. 14, 2025 (recounting
Attorney General Griffin Bell speech to Justice Department lawyers to address Watergate’s
fallout). And if I thought that an oath was enough to bind anyone in power in this grotesque
caricature of an administration, I would not bother this Court—but the evidence screams
otherwise.
There also appears to be an element of quid pro quo reminiscent of The Godfather: Trump
pardoned her ex-husband Albert, “convicted nearly two decades ago on 34 counts of con-
spiracy and tax evasion after he was found to have improperly deducted over $1 million in
lavish personal expenses as a tax write-off for his business.” Lucien Bruggeman, Trump
issues last-minute pardon to ex-husband of Fox News' Jeanine Pirro, ABC News, Jan. 20,
2021. Kiss The Don’s ring, get a favor?

9. While Petitioner is going through the motions of requesting that the Attorney General and

local U.S. Attorney act on this petition, given these resumes, doing so is an act of futility.

16
E.g., Laura Loomer, X (July 8, 2025, 6:36 PM), https://x.com/LauraLoomer/status/1942654080909775144 (citing
[ostensible] FBI document from 2008); Benny Johnson, X (July 9, 2025, 1:50 PM), https://x.com/bennyjohnson/sta-
tus/1942763354621370669; Gunther Eagleman, X (July 8, 2025, 6:35 PM), https://x.com/GuntherEagleman/sta-
tus/1942653846087688455. Elon weighs in: “How can people be expected to have faith in Trump if he won’t release
the Epstein files?” Elon Musk, X (July 8, 2025, 6:33 PM), https://x.com/elonmusk/status/1942653394168246464.

11
 10. A remedy “may be inadequate where the administrative body is shown to be biased,”

McCarthy v. Madigan, 503 U.S. 140, 149 (1992), and the law does not ask that a litigant “commit

a futile act.” Houghton v. Shafer, 392 U.S. 639, 640 (1968) (citations omitted).

ALLEGATIONS OF FACT

11. On or about January 20, 2017, in the process of becoming President of the United States,

Respondent Donald John Trump (“Trump”) swore the following oath: “I do solemnly swear that I

will faithfully execute the Office of President of the United States, and will to the best of my

Ability, preserve, protect and defend the Constitution of the United States."17

12. Upon a five-day trial on the merits in which Respondent Trump participated as a party, a

court of competent jurisdiction18 found via “clear and convincing evidence” that “Trump engaged

in an insurrection on January 6, 2021 [against the United States19] through incitement.” Anderson

v. Griswold, No. 23CV32577, ¶¶ 209, 298 (Dist. Ct., City & Cnty. of Denver, Nov. 17, 2023).

13. The trial court’s finding that Respondent Trump engaged in insurrection against the United

States was not disturbed on appeal. Anderson-CO, supra, Trump v. Anderson, 601 U.S. 100 (2024).

17
This fact was stipulated to in the civil trial. “Intervenor Donald J. Trump served as 45th President of the United
States from January 20, 2017, to January 20, 2021. Id. ¶ 8. On January 20, 2017, Trump took the Presidential Oath of
Office, swearing to “faithfully execute the Office of President of the United States,” and “to the best of [his] Ability,
preserve, protect and defend the Constitution of the United States.” U.S. CONST. art. II, § 1, cl. 8; Stipulation ¶ 9.”
Anderson v. Griswold, No. 23CV32577, ¶ 56 (Dist. Ct., City & Cnty. of Denver, Nov. 17, 2023).
18
A “court of competent jurisdiction” is a court that has both subject matter jurisdiction and personal jurisdiction
over the party against which collateral estoppel is sought, as well as any other jurisdictional requirements nec-
essary to adjudicate the dispute. Pennoyer v. Neff, 95 U.S. 714, 722–23 (1878); Restatement (Second) of Judg-
ments § 1 (1982). Colorado district courts are “trial courts of record with general jurisdiction … [with] original
jurisdiction in all civil, probate, and criminal cases,” with irrelevant exceptions. Colo. Const. art. VI, § 9(1).
Trump intervened and tried to remove the case to federal court, Anderson v. Griswold, 543 P.3d 283, 298 (Colo.
2023) (hereinafter, “Anderson-CO”), and his voluntary appearance constitutes consent to the court’s jurisdiction.
Adam v. Saenger, 303 U.S. 59, 67-8 (1938). And it has been settled law that state courts have concurrent juris-
diction over federal claims since Colorado became a state. Claflin v. Houseman, 93 U.S. 130 (1876). Ergo, the
Denver District Court was competent to hear the issue.
19
“In short, the record amply established that the events of January 6 constituted a concerted and public use of force
or threat of force by a group of people to hinder or prevent the U.S. government from taking the actions necessary to
accomplish the peaceful transfer of power in this country.” Anderson v. Griswold, 543 P.3d at 331.

12
 14. Respondent Trump is collaterally estopped from contesting the trial court’s finding that he

engaged in insurrection against the United States.20

15. Section 3 of the Fourteenth Amendment to the United States Constitution provides:

No person shall be a Senator or Representative in Congress, or elector of President and

Vice President, or hold any office, civil or military, under the United States, or under any
state, who, having previously taken an oath, as a member of Congress, or as an officer of
the United States, or as a member of any state legislature, or as an executive or judicial
officer of any state, to support the Constitution of the United States, shall have engaged in
insurrection or rebellion against the same, or given aid or comfort to the enemies thereof.
But Congress may by a vote of two-thirds of each House, remove such disability.

15. The Constitution in general, and the Fourteenth Amendment in particular, is self-executing.

Marbury v. Madison, 5 U.S. at 177; see generally, fn. 1, supra.

16. As evidenced by their treatment of oathbreaking insurrectionist Col. Nathan Tift, the fram-

ers of the Amendment regarded it as self-executing. See fn. 1, supra.

17. By its terms, “not being an oathbreaking insurrectionist” is a qualification for office, no

different from being a natural-born citizen of appropriate age. U.S. Const. art. II, § 1, cl. 5.

18. Congress has not, “by a vote of two-thirds of each House,” removed Respondent Trump’s

“disability.” See U.S. Const. amend. XIV, § 3.

19. In a merits brief submitted to the Supreme Court, Respondent Trump admits that Section 3

“does not prevent anyone from running for office, or from being elected to office, because

20
Issue preclusion generally bars relitigation when: (1) the issue “being raised must have been contested by the parties
and submitted for judicial determination in the prior case”; (2) it “must have been actually and necessarily determined
by a court of competent jurisdiction in that prior case,” and (3) it “must not work a basic unfairness to the party bound
by the first determination.” Yamaha Corp. of America v. United States, 961 F. 2d 245, 254 (D.C. Cir. 1992); Parklane
Hosiery Co. v. Shore, 439 U.S. 322, 326 n. 5 (1979).
The Parklane Court identifies situations where it would be unfair to apply the doctrine, but none of them seem to
apply. If a billionaire is sued for petty cash, he might have “little incentive to defend vigorously, particularly if future
suits are not foreseeable.” Parklane, 439 U.S. at 330. Similarly, a plaintiff might lie in wait, letting others establish
the law controlling in the case before taking advantage of his adversary. Id. But as Trump fought Anderson all the
way to the Supreme Court, where the quality of justice you get is a function of your exchequer, see e.g., Marshall v.
Marshall, 547 U.S. 293 (2006); Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U. S. 280 (2005), and the
original lawsuit appeared meritless—owing to the fact that Congress could have removed the disability—any sugges-
tion of “basic unfairness” is facially risible.

13
Congress can remove a section 3 disqualification after a candidate is elected but before his term

begins,” further conceding that “Section 3 prohibits individuals only from holding office.” Brief

for Petitioner, Trump v. Anderson, No. 23-719, 41 (U.S. Jan. 18, 2024) (emphasis in original).21

20. In a reply brief submitted to the Supreme Court, Respondent Trump did not contest the self-

executing nature of Section 3, stating that he “is not arguing that section 3 is ‘non-self-executing.’

His claim is that section 3 may be enforced only through the congressionally enacted methods of

enforcement.” Br. for Petitioner in Reply, Trump v. Anderson, No. 23-719, 19 (U.S. Feb. 5, 2024).

21. As the only question of law properly before our United States Supreme Court in Trump v.

Anderson was whether “the Colorado Supreme Court err[ed] in ordering President Trump ex-

cluded from the 2024 presidential primary ballot,” Trump v. Anderson, No. 23–719, 601 U.S. 100

(2024), Pet. Br. at (i), the question of whether Trump could legally serve as President was never

before that Court.

22. As Congress could have removed Trump’s disability at any time prior to his ostensible

ascension to office if it so chose, the ratio decedendi of Trump v. Anderson, supra.—that States

may not prevent an oathbreaking insurrectionist from appearing on a primary ballot—was both

correct and binding.

23. As a quo warranto action is sufficient to enforce Section 3 of the Fourteenth Amendment,

see The Enforcement Act of 1870, § 14, 16 Stat. 140, 143 (1870); repealed, Act of June 25, 1948,

ch. 646, § 39, 62 Stat. 869, 993 (1948), the Supreme Court’s extemporaneous discussion in Trump

21
As Respondent Trump concedes, Congress has, in their infinite wisdom, removed the disability on numerous
occasions: “See Cong. Globe, 40th Cong., 2d. Sess., 4499 (July 25, 1868); Cong. Globe, 40th Cong., 3d. Sess., 13–
14 (Dec. 7, 1868); Cong. Globe, 40th Cong., 3d. Sess., 120–121 (Dec. 17, 1868); see also id. (statement of Senator
Sawyer) (“It is necessary that the disabilities should be removed from these persons before the recess, in order to
enable them to qualify for offices to which they have been elected before the 1st of January. . . . [T]hey are men who
were selected by the votes of their several localities to fill important local offices.”).”” Trump v. Anderson, Br. for
Pet. at 41.

14
v. Anderson, supra, about the need for another statute to enforce it is obiter dictum, as well as an

incomprehensibly attempt to overturn Marbury v. Madison, supra., and a long line of precedent.

A. Voltaire: “Il Est Dangereux D'avoir Raison….”

America has never tasted the jackboot of fascism, but Defendant Trump is bring-
ing it to our door at a level "like nobody's ever seen before." To take root, Fascism
requires ignorance and fear. The autocrats’ ultimate goal is to control the infor-
mation space by stifling dissent. Opposition leaders are targeted, and the judiciary
is stripped of its independence. See e.g., Lydia Gall, Hungary’s Latest Assault on
the Judiciary, Human Rights Watch, Dec. 14, 2018. Journalists become targets early
on because authoritarians know that controlling information is key to maintaining
power. Ruth Ben-Ghiat, Strongmen: Mussolini to the Present (Norton: 2020). As
Trump’s war on the information space, waged from the White House, is violative
of the Constitution, Virginia State Bd. of Pharmacy v. Virginia Citizens Consumer
Council, 425 U.S. 748 (1976), and Plaintiff is currently being harmed by the De-
fendants’ actions, Plaintiff has standing to proceed.

24. Whereas Petitioner is cognizant of Andrade v. Lauer, 729 F. 2d 1475 (D.D.C. 1984), Justice

Barrett cast grave aspersions on the doctrine of standing, by chastising Justice Jackson last week

in a frameworthy rant:

We will not dwell on JUSTICE JACKSON’s argument, which is at odds with more than
two centuries’ worth of precedent, not to mention the Constitution itself. … JUSTICE
JACKSON would do well to heed her own admonition: “[E]veryone, from the President
on down, is bound by law.” Ibid. That goes for judges too.

Trump v. CASA, Inc., No. 24A884, 606 U.S. ___ (2025) (Application for Stay granted Jun. 27,

2025), slip. op. at 23, 24 (capitalization in original) (emphasis added).

25. Much as the “nationwide injunction” is a judicial invention of recent vintage, the doctrine

of “standing” in public interest litigation was grafted onto the Constitution by the Taft Court, hav-

ing no foundation in either it or the underlying common law, Berger, supra.; Jaffe, supra., and is

therefore void on its face.

15
 26. However, as Petitioner has conventional standing in spades, this Court should not dismiss

this Petition on that ground. Two bases for standing are illustrative:

a. Petitioner has a legally cognizable interest in a free press—able to perform its function

in society, unencumbered by illicit pressure from Washington. Virginia State Bd. of Phar-

macy, 425 U.S. at 756–57 (citizen’s right to receive information free from government in-

terference): Both ends of the information superhighway are protected by the First Amend-

ment, so that the citizen may serve his intended function as ultimate superintendent of gov-

ernment.

b. Petitioner also has a legally cognizable interest in a free society—where the price of

voicing dissent is not a one-way ticket to a gulag in El Salvador—for “if Men are to be

precluded from offering their sentiments on a matter, which may involve the most serious

and alarming consequences, that can invite the consideration of Mankind; reason is of no

use to us—the freedom of Speech may be taken away—and, dumb & silent we may be led,

like sheep, to the Slaughter.” George Washington, Speech (Newburg, NY), Mar. 15, 1783.

28. As Judge J. Harvie Wilkerson recently observed, the threat to American citizens is no longer

theoretical:

If today the Executive claims the right to deport without due process and in disregard of
court orders, what assurance will there be tomorrow that it will not deport American citizens
and then disclaim responsibility to bring them home?∗ And what assurance shall there be
that the Executive will not train its broad discretionary powers upon its political enemies?
The threat, even if not the actuality, would always be present, and the Executive’s

16
 obligation to “take Care that the Laws be faithfully executed” would lose its meaning. U.S.
CONST. art. II, § 3; see also id. art. II, § 1, cl. 8.

Abrego-Garcia v. Noem, No. 25-1404, slip op. at 5 (4th Cir. Apr. 17, 2025) (emphasis added).

Footnote in opinion: See, e.g., Michelle Stoddart, ‘Homegrowns are Next’: Trump Doubles Down

on Sending American ‘Criminals’ to Foreign Prisons, ABC NEWS (Apr. 14, 2025, 6:04 PM); David

Rutz, Trump Open to Sending Violent American Criminals to El Salvador Prisons, FOX NEWS

(Apr. 15, 2025, 11:01 AM EDT).

27. As an author and scholar, Petitioner has an identifiable and personal interest in receiving

full and accurate information, and in the infamous words of Donald Rumsfeld, “there are also

unknown unknowns—the ones we don’t know we don’t know.” Donald Rumsfeld, Press Brief-

ing, Dept. of Defense, Feb. 12, 2002 (emphasis added). Knowledge is power, a current which the

Defendants have illicitly short-circuited.

28. As a politically active and law-abiding citizen cursed with a sharp tongue who has partici-

pated in protests against the Respondent’s regime and can reasonably be expected to do so in the

future, Petitioner has an identifiable and personal interest in being free from arbitrary arrest and

detention.

29. On information and belief, in light of the illegitimate and activist Supreme Court decision

granting an almost plenary immunity to the President from criminal liability,22 the unfettered

22
“WE HAVE A KING!” DECLARING TRUMP V. UNITED STATES

17
 As Clarence Thomas solemnly observes, "[w]e should always start, when we read the Constitution, by reading the
Declaration [of Independence], because it gives us the reasons why the structure of the Constitution was designed the
way it was." Clarence Thomas, A Conversation with Justice Clarence Thomas, 36-10 Imprimis (Oct. 2007). The
Framers designed their Constitution to prevent unchecked executive power—a principle rooted in their experience
under King George III, as chronicled in the Declaration.

To a man, the Framers were adamant in their opposition to a grant of criminal immunity to the President. James
Wilson told the Pennsylvania ratifying convention that the president was “far from being above the laws,” and “not a
single privilege [was] annexed to his character.” 2 Elliot’s Debates 480. Contrasting the President to the King, Alex-
ander Hamilton assured the public that the president, unlike a monarch, “would be liable to prosecution and punish-
ment in the ordinary course of law.” The Federalist No. 69, 396-97 (Hamilton). Some years later, Charles Pinckney
confirmed that “[n]o privilege of this kind was intended for your Executive, nor any except that which I have men-
tioned for your Legislature.” Sen. Charles Pinckney (D/R-SC), Speech (in the United States Senate), Mar. 5, 1800, 3
Farrand 384-85. Noting “no subject had been more abused than privilege,” he added that the Framers “set the example
in merely limiting privilege to what was necessary, and no more.” Id. There is no contrary authority.’
Whereas the Framers’ public views carry the most probative value, it was generally understood that the president’s
accountability to prosecution would distinguish American leaders from European monarchs. In a September 1787
essay, Tench Coxe emphasized that the president could be “proceeded against like any other man in the ordinary
course of law.” An American Citizen I, Indep. Gazetteer (Philadelphia, Pa.) (Sept. 26, 1787), reprinted in 2 Documen-
tary History of Ratification (“DHR”) 138, 141. As “Americanus,” a supporter of the Constitution from New Jersey,
observed, the British king was “above the reach of all Courts of law,” but this “prerogative[]” was not “vested in the
President.” Americanus II, N.Y. Daily Advertiser (Nov. 23, 1787), reprinted in 19 DHR 287, 288-89. Patrick Henry
found this to be a flaw asserting that “we may prescribe the rules by which he shall rule his people, and interpose such
checks as shall prevent him from infringing them, but the President, in the field, at the head of his army, can prescribe
the terms on which he shall reign,” 3 Elliot’s Debates 59-60 (Patrick Henry) (noting in opposition to the president’s
control over the army in the draft Constitution that a president who committed a crime might try to use the army to
avoid “being ignominiously tried and punished”), presaging the concern Justice Sotomayor voiced in her dissent.
Senator William Maclay (Anti-Administration-PA) asked what would happen in the case of a murderous president:
“Suppose the President committed murder in the street. Impeach him? . . . But [suppose] . . . he runs away. But I will
put up another case. Suppose he continues his murders daily, and neither House is sitting to impeach him.” William
Maclay, The journal of William Maclay, United States Senator from Pennsylvania, 1789-1791, 163 (Chas. A. Beard
ed., 1927) (1965). “Senator William Grayson of Virginia was adamant that the ‘President was not above the law,’
arguing that presidents likely would be sued and that they might be prosecuted for murder.” Saikrishna Prakash, Pros-
ecuting and Punishing Our Presidents, 100 Tex. L. Rev.55, 74-5 (2021). Others underscored that the president could
be “tried for his crimes,” see Publicola: An Address to the Freemen of North Carolina, State Gazette of N.C. (Mar.
27, 1788), reprinted in 30 DHR Digital Edition 113, 116 (Kaminski et al. eds., 2009) and was “liable . . . to be indicted
if the case should require it,” see A Freeholder, Va. Indep. Chron. (Apr. 9, 1788), reprinted in 9 DHR 719, 723. The
Federal Farmer was more concerned that the President would use his office to get re-elected, “Federal Farmer,” The
Character of the Executive Office, Antifederalist No. 69, reprinted at https://www.history1700s.com/index.php/the-
united-states-constitution-reference/the-anti-federalist-papers/1178-antifederalist-no-69.html. On the privileges of
king and lords, Tucker states: “The fundamental principle of the American Constitutions and governments, being the
perfect equality of rights, there was no room to admit any thing therein, that should bear the most distant resemblance
to the subject of this chapter.” 2 St. George Tucker, Blackstone’s Commentaries 219 n.1. (1803). As Chief Justice
Marshall put it, “the president is elevated from the mass of the people and, on the expiration of the time for which he
is elected, returns to the mass of the people again.” United States v. Burr, 25 F. Cas. 30, 34 (C.C.D. Va. 1807) (Mar-
shall, C.J., riding circuit) (emphasis added). Therefore, “the first magistrate of the Union may more properly be likened
to the first magistrate of a state,” rather than to a “monarch.” Id. Again, there is no contrary authority.
Unlike the question of criminal immunity, the efficacy of impeachment was discussed by the Framers. The danger
being guarded against, in the words of Madison, was that “the chief Magistrate … might pervert his administration
into a scheme of peculation or oppression [or] betray his trust to foreign powers.” Notes on the Constitutional Con-
vention (July 20, 1787), 2 Farrand 65-66. Colonel Mason all but predicted a crime Mr. Trump was indicted for: “Shall
the man who has practised corruption [through bribing Electors] & by that means procured his appointment in the first
instance, be suffered to escape punishment, by repeating his guilt?” Id. at 65. Ben Franklin, in reasoning against any

18
monarchical-like system which would place the chief executive beyond the reach of the law, argued it would be “best
... to provide in the Constitution for the regular punishment of the Executive when his misconduct should deserve it.”
Id. When Ben Franklin disagrees with you, you probably need to double-check your work
Consistent with this view, the Framers made it a point not to grant immunity from criminal prosecution to the
President. No reference can be found in the Constitution, its penumbrae, or its emanations. See Antonin G. Scalia,
Historical Anomalies in Administrative Law, Y.B. Sup. Ct. Hist. Soc’y. 103 (1985). Presidential immunity has no
“grounding in constitutional text, history, or precedent.” Dobbs v. Jackson Women’s Health Organization, 597 U.S.
215, 280 (2022), 142 S. Ct. 2228.
The King can do no wrong, in a land without a king. To even state the majority Justices’ declaration in Trump v.
United States, 603 U.S. 593 (2024), is to refute it. But what is important here is what was taken away. One of the
blessings of liberty the Framers gave us was the freedom not to be harmed by the King for any reason or no reason at
all. In the Framers’ day, if the President committed a crime against you, you could initiate a private criminal prose-
cution. See e.g., Emma Kaufman, The Past and Persistence of Private Prosecution, 173 U.Penn.L.Rev. 89 (2024-25)
(chronicling the history of and judicial erosion of the right, which still is in force in some form all over the civilized
world). But after Trump v. United States, if the President wanted to grab you off the street and send you to a gulag
half-way around the world, there would literally be nothing you could do about it: He could pardon his minions and
then, hide behind a cloak of judicially conjured immunity.
What makes this covert judicial flight to El Salvador so outrageous is that none of the Justices were not writing
from a blank slate. Everything they said on the record beforehand would have led the reasonable citizen to believe
that they had all concluded that the notion that our President enjoyed almost limitless immunity from criminal prose-
cution was fifty shades of absurd.
Prior to issuing the ruling in Trump v. United States, Justice Kavanaugh admitted that the President did not enjoy
criminal immunity. As he was an adjunct professor at Harvard who worked for independent counsel Kenneth Starr
and had written a scholarly piece on the subject, Brett M. Kavanaugh, The President and the Independent Counsel, 86
Geo. L.J. 2133 (1998), his was the most full-throated answer:
“No one has ever said, I do not think, that the president is immune from civil or criminal process,” Kavanaugh
said. “So immunity is the wrong term to even think about in this process.” He added, “But immunity is not —
not the correct word, and I do not think anyone thinks of immunity. And why not? No one is above the law.
And that is just such a foundational principle of the Constitution and equal justice under law.”
Aaron Blake, What conservative justices said about immunity — before giving it to Trump, Wash. Post, Jul. 2, 2024
(hereinafter, “Blake”). And in a response to Senator Grassley (R-IA) regarding suspicion that he would rule that the
President enjoys broad immunity from criminal liability, he explained why:
No one is above the law in our constitutional system. Federalist 69, Hamilton makes clear all the ways that the
executive branch, as designed by the Framers of the Constitution, was different from the monarchy. Under our
system of Government, the executive branch is subject to the law, subject to the court system, and that is an
important part of Federalist 69. It is an important part of the constitutional structure.
S. Hrg. 115-545, Pt. 1, Confirmation Hearing on the Nomination of Hon. Brett Kavanaugh to be an Associate Justice
of the United States 119 (Sept. 4-7, 2018) (stmt. of Judge Kavanaugh). Similar statements from the hearing are com-
piled in video form. Conover Kennard, Brett Kavanaugh In 2018 Disagrees With Brett Kavanaugh of 2024,
Crooks&Liars.com, Jul. 2, 2024, https://crooksandliars.com/cltv/2024/07/brett-kavanaugh-2018-disagrees-brett
(video only).
Although examined less directly, when asked whether a President had criminal immunity, all the other named
Justices agreed under oath that he did not. When they were applying for the job of Justice, the Justices averred that
“no man was above the law.” (“I believe that no one is above the law under our system, and that includes the President.
The President is fully bound by the law, the Constitution and statutes.” S. Hrg. 109–158, Confirmation Hearing on
the Nomination of John G. Roberts, Jr. to be Chief Justice of the United States 152 (2005) (stmt. of Judge Roberts);
“No man is above the law. … No man.” S. Hrg. 115–208, Confirmation Hearing on the Nomination of Hon. Neil
Gorsuch to be an Associate Justice of the United States 113 (2017) (stmt. of Judge Gorsuch); “Barrett said three times
that nobody was ‘above the law’ while responding to questions about the president” and Alito stated that “no person
in this country is above the law, and that includes the president and it includes the Supreme Court.” Aaron Blake,

19
pardon power, and de facto control of the mechanism of federal law enforcement, the citizen has

no practical defense against the criminal depredations of the new Crown.

30. On information and belief, in a notorious incident, Respondent Trump has used the powers

of the Presidency to imprison a writer critical of him, Cohen v. Barr, No. 20-CV-5614 (S.D.N.Y.

July 23, 2020)— U.S. District Judge Alvin K. Hellerstein ordered Cohen’s release to home con-

finement, finding that the government’s reimprisonment was “retaliatory in response to Cohen

What conservative justices said about immunity — before giving it to Trump, Wash. Post, Jul. 2, 2024). But without
any colorable support in or reference to the law—and in inexplicable disregard of their own public positions—the
Justices decided sua sponte that Presidents ought to be above the law. Never mind that they all admitted that making
policy decisions was above their pay grade. Ergo, at the time they were asked to consider the case, by all rights, they
should have been predisposed to not even grant certiorari review.
But it gets worse. The majority opinion, written by Chief Justice Roberts, indulged in a policy-driven argument.
There may even be reasonable arguments for why a President should be immune from criminal prosecution. But as
Chief Justice Roberts had asserted, “Members of this Court are vested with the authority to interpret the law; we
possess neither the expertise nor the prerogative to make policy judgments. Those decisions are entrusted to our Na-
tion's elected leaders, who can be thrown out of office if the people disagree with them.” Nat. Fedn. of Indep. Business
v. Sebelius, 567 U.S. 519, 132 S.Ct. 2566, 2579 (2012).
This should freeze the blood of any American. In a raw exercise of power, the majority gave a petty and vindictive
dictator-in-training the power of an Emperor, in flagrant disregard of our laws. They did it arbitrarily, and without
regard for the Constitution, legislative history, and common sense. This is a patent violation of their good behavior
tenure, and grounds for removal.
Article III judges “shall hold their Offices during good Behaviour.” U.S. Const. art. III, § 1. English law sourced
in Coke and Blackstone defines this facially abstruse term of legal art with remarkable precision. By making a public
official subject to removal for violating it, the condition of “good behavior” defined the powers of any given office.
Coke listed three grounds for forfeiture of good behavior tenure: abuse of office, nonuse of office, and willful refusal
to exercise an office. R. v. Bailiffs of Ipswich [1706] 91 Eng. Rep. 378 (K.B.) (corporate recorder forfeited office for
failure to attend corporate meetings); Henry v. Barkley [1596] 79 Eng. Rep. 1223, 1224 (K.B.); see generally, Raoul
Berger, Impeachment of Judges and “Good Behavior” Tenure, 79 Yale L.J. 1475 (1970); Saikrishna Prakash & Ste-
ven D. Smith, How to Remove a Federal Judge, 116 Yale L.J. 72, 88-128 (2006). Blackstone adds "oppression and
tyrannical partiality of judges, justices, and other magistrates, in the administration and under the colour of their of-
fice." 4 Blackstone, Commentaries *140.
American judges are fairly noticed on what conduct might get them fired. When an Article III judge is elevated to
the federal bench, s/he swears an oath to "administer justice without respect to persons, and do equal right to the poor
and to the rich, and ... faithfully and impartially discharge and perform all the duties incumbent upon" him or her, 28
U.S.C. § 453, thereby defining the scope of his duties and obligations. In short, a violation of good behavior tenure
is a violation of the oath of office, which has not changed since the Judiciary Act of 1789, 1 Stat. 73, § 8 (1789). At
common law, good behavior tenure was intended to be enforced by the citizen using a writ of scire facias; in Britain,
it was technically a writ of the King, but any subject could wield it. 3 Blackstone, Commentaries at 260-61 (1765)
(emphasis added); see, United States v. American Bell Tel. Co., 28 U.S. 315, 360 (1888) (explaining the process). In
medieval England, royal letters patent granted a variety of offices (e.g., postmasters, judges), 4 Coke, Inst. 117, revo-
cable by scire facias for misbehavior. See generally, Berger, How to Remove a Federal Judge, supra.)

20
intending to exercise his First Amendment rights to publish a book critical of the President and to

discuss the book on social media.” Id., ECF #30.

31. Based on court rulings, in administration of the office of the Presidency, Respondent and

his agents have demonstrated open and notorious contempt for the rule of law and judicial orders

expounding it on repeated occasions. E.g., Abrego-Garcia v. Noem, supra. (defiance of court

order); J.G.G. v. Trump, No. 25-766 (JEB) (D.D.C. Apr. 16, 2025) (probable cause for finding of

contempt); see e.g., Alison Durkee, Could Trump Officials Be Prosecuted? What To Know After

Judge Finds Evidence Of Criminal Contempt For El Salvador Flights, Forbes, Apr. 16, 2025.

32. On information and belief, Respondent Trump is building an enormous secret police force

(photo above), manned by gangs of unknown masked gunmen with zero accountability, reminis-

cent of Russia’s siloviki.23

33. On information and belief, Respondent Trump has used the office of the President to intim-

idate and browbeat mainstream media outlets and universities into altering their coverage to con-

form with his view of the world, and the law firms24 Petitioner might need to defend his legal

interests. See e.g., the Washington Post—which Petitioner subscribes to.25

23
One Big Beautiful Bill Act, H.R. 1, § 100052, 119th Cong. (2025) (appropriating $29,850,000,000 to U.S. Immi-
gration and Customs Enforcement for enforcement and deportation operations, including personnel recruitment, trans-
portation, 287(g) program expansion, facility upgrades, fleet modernization, and support for victims of immigration
crimes, available until September 30, 2029). This is at least a ten-fold increase in funding, begging the question of
why it would be needed. Between Presidential immunity, pardons, and plenary control of the gears of prosecution,
any act committed by Trump’s enormous private army would be unreachable by the arm of the law.
24
On information and belief, Respondent Trump’s in terrorem campaign against major law firms transforms some of
the world’s most capable firms (here, Skadden, Arps) into his own in-house lawyers, working on his “pet projects.”
Brenna Trout Frey, Skadden Resignation (LinkedIn), reprinted at Anna Bower (@AnnaBower), X (Mar. 28, 2025,
11:42 PM), https://x.com/AnnaBower/status/1905767419765018936; Daniel Barnes, Major law firm strikes preemp-
tive deal with White House, Politico, Mar. 28, 2025 ($100,000,000 anticipatory capitulation arrangement).
25
The Washington Post is one of the two de facto “papers of record” in America, traditionally serving as a reliable
first draft of history. On information and belief, the Post is owned by centi-billionaire Jeff Bezos. Benjamin Mullin
and Katie Robertson, A Decade Ago, Jeff Bezos Bought a Newspaper. Now He’s Paying Attention to It Again, N.Y.
Times, Jul. 23, 2023. On information and belief, Bezos is the largest shareholder of e-commerce megalith Amazon,
and those holdings comprise a large portion of his wealth. Notice of 2024 Annual Meeting of Shareholders & Proxy
Statement, Amazon, Inc., May 22, 2024, at 84.

21
 34. On information and belief, even the White House Correspondents’ Association has surren-

dered, preemptively canceling comedian (and fierce Trump critic) Amber Ruffin as the headliner

for its annual dinner. Giselle Ruhiyyih Ewing, White House Correspondents’ Association cancels

comedian headliner for annual dinner, Politico, Mar. 29. 2025.

35. Respondent Trump has used objectively baseless lawsuits backed by his privileged position

to extort funds from major media outlets and cement his dominance. E.g., Trump v. Selzer, No.

In 2024, the Washington Post refused to endorse a candidate for President. David Folkenflik, 'Washington Post'
won't endorse in White House race for first time since 1980s, NPR, Oct. 25, 2024. On information and belief, the
refusal to endorse was not a principled decision, but one of genuflection toward Defendant Trump. David Bauder,
Newspaper non-endorsements at Washington Post, LA Times fit a trend, but their readers aren’t happy, AP, Oct. 29,
2024; Several editorial board members resigned, and “Washington Post legends Bob Woodward and Carl Bernstein
issued a statement saying: ‘We respect the traditional independence of the editorial page, but this decision 12 days out
from the 2024 presidential election ignores the Washington Post’s own overwhelming reportorial evidence on the
threat Donald Trump poses to democracy.’” Manuel Roig-Franzia and Laura Wagner, The Washington Post says it
will not endorse a candidate for president, Wash. Post, Oct. 25, 2024. Observing that “it is asking a lot of readers not
to suspect that Bezos’s personal business interests play no role” in his editorial changes, veteran columnist Ruth Mar-
cus recently re-signed from the Post. Ruth Marcus, Why I Left the Washington Post, The New Yorker, Mar. 12, 2025.
On information and belief, Bezos is currently in the process of decapitating the Washington Post reporting staff,
replacing them with right-wing ideologues. Erkki Forster, The Washington Post Looks to Recruit Right-Wing Jour-
nalists, The Daily Beast, Mar. 5, 2025. On information and belief, Bezos’ payments to the Trump family and editorial
shift function as a de facto inducement or quid pro quo arrangement to secure favorable USPS access and shield
Amazon from anti-trust enforcement under the Trump Administration. Grok summarizes the new Apprentice airing
thusly: “In short, Amazon hasn’t ‘bought’ the rights anew in 2025; it leverages its existing MGM ownership to
stream The Apprentice, reinforcing its strategic ties with the Trump family as of March 27, 2025,” describing “Ama-
zon’s pattern of Trump-related investments.” Grok 3, Mar. 28, 2025 (Query: “Has Amazon bought the rights to The
Apprentice?”; screenshots retained). Musk describes Grok 3 as "the smartest AI on earth," Matt High, Why Elon Musk
Claims Grok-3 is the World's 'Smartest AI', AI Magazine, Feb. 19, 2025, and Plaintiff need not quibble here.
Amazon’s antitrust exposure could have a seismic effect on its market value. Defendant Trump is known to have
had a long-standing relationship with DeutscheBank; while New York and U.K. regulators slapped the bank with a
combined $630 million fine for Russian money laundering, Karen Freifeld and Arno Schuetze Deutsche Bank fined
for $10 billion sham Russian trades, Reuters, Jan. 31, 2017, federal regulators under Trump made a similar probe ‘go
away’; “The DOJ investigation has been closely watched by Democrats on Capitol Hill who have tried and failed to
get Deutsche Bank to turn over its internal investigation into the Russian trades and a separate internal review into
whether bank accounts of President Donald Trump and his family have any ties to Russia.” Kara Scannell, DOJ Probe
on Russian Trades Through Deutsche Bank Quiet, CNN Politics, Nov. 15, 2017. Russia, Russia, Russia! Guess it
pays to know the Boss.
On information and belief, the relationship between Bezos’ financial dealings with Defendant Trump and editorial
shifts at the Washington Post cannot be seen as coincidental but instead, reflects his self-censorship of the Post under
implicit coercion, fearing Trump’s retaliation if he does not comply. Bezos’ behavior mirrors that of journalists and
media outlets in authoritarian regimes, where leaders use legal threats, financial ruin, or physical harm to induce self-
censorship: “The strongman’s media strategy often relies on intimidation rather than outright bans, encouraging self-
censorship among journalists and outlets eager to survive.” Ruth Ben-Ghiat, Strongmen: Mussolini to the Present 112
(Norton: 2020).

22
4:24-cv-00449 (S.D. Iowa filed Dec. 17, 2024), (complaining about a Des Moines Register opinion

poll), Trump v. CBS News, No. 2:24-cv-00206, (N.D. Tex., filed Oct. 31, 2024) (alleged deceptive

editing of a 60 Minutes interview with Kamala Harris, seeking $10 billion), Trump v. Simon &

Schuster, No. 2:23-cv-00068 (M.D. Fla. filed Jan. 30, 2023) (Donald Trump lies; Bob Woodward

tapes everything): With a pending merger and FCC factors clearly central to Paramount’s decision

to capitulate, this episode underscores the growing ease with which political power can be wielded

to shape editorial outcomes in American media. Sara Fischer, Paramount agrees to settle Trump

lawsuit for $16 million, Axios, Jul. 2, 2025.

36. On information and belief, Respondent Trump indicated his intention to weaponize the

Department of Justice in an effort to assert dominance over the information space in a speech:

“The Washington Post, The Wall Street Journal and MSDNC, and the fake news, CNN and
ABC, CBS and NBC, they’ll write whatever they say,” Trump said. “And what do you do
to get rid of it? You convict Trump.”
“It’s totally illegal what they do,” Trump continued, addressing DOJ employees. “I just hope
you can all watch for it, but it’s totally illegal.”
While Trump did not immediately clarify who “they” are, he later claimed that CNN and
MSNBC are “political arms of the Democrat Party.”

Liam Reilly, Trump baselessly accuses news media of ‘illegal’ behavior and corruption in DOJ

speech, CNN, Mar. 14, 2025.

37. Viewed in pari materia, Respondent’s actions constitute an ongoing and direct infringement

on Petitioner’s First Amendment rights to receive information, engage in political advocacy, and

access legal representation without fear of state-coerced retaliation, as both ends of the proverbial

“firehose of information” protected by the First Amendment are currently and will continue to be

materially impaired. E.g., Virginia State Bd. of Pharmacy, supra.

23
 CONCLUSION

The Constitution is a stern mistress, which does not brook infidelity. I didn’t make
the rules, but have a right to insist that they be followed scrupulously. Respondent Donald
Trump cannot be our President because the Constitution says so.

It is “a general and indisputable rule, that where there is a legal right, there is also a
legal remedy by suit, or action at law, when ever that right is invaded." Marbury v. Mad-
ison, 5 U.S. at 163 (quoting Blackstone). "Every [English] subject,' said Justice Lush,
"has an interest in securing that public duties shall be exercised only by those competent
to exercise them." Berger, Standing to Sue, 78 Yale L. Rev. at 823 & n. 39. To achieve
that end, our legislators have passed the statutory remedy invoked in this Petition.

As Justice Roberts observed, “the Government should turn square corners in dealing
with the people.” Dep’t of Homeland Sec. v. Regents of the Univ. of California, 591 U.S.
1, 24 (2020) (quoting Justice Black). It seems redundant to swear out an oath in a petition
where I am obliged to tell the truth to the Court already. It seems absurd for me to attest
personally to facts which are judicially noticeable. I have stated controlling law to the
best of my ability. I am entitled to rely to an appropriate degree on the news of the day,
and indicate said reliance. Legal conclusions grounded in judicially noticeable facts need
no further support. On these points, the law can ask no more. What remains is the legally
protected interests I seek to vindicate, which I attest to—without reservation—herein,
under oath.

The controlling statute grants federal authorities a right of first refusal, but for reasons
stated herein, those designated authorities are structurally and ethically compromised.
Where further delay would be inimical to the statute’s purpose, and where waiting would
almost certainly be futile, this Court has the equitable power to proceed. McCarthy, su-
pra., Houghton, supra. I therefore respectfully request that the Court waive the statutory
notice requirement and issue the writ of quo warranto without delay.

I declare under penalty of perjury under the laws of the United States that the foregoing is true
and correct to the best of my knowledge and belief.

FURTHER AFFIANT SAYETH NOT.

Dated: ________________, 2025

_____________________________________

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